In an effort to support the global harmonization efforts of the International Civil Aviation Organization (ICAO), the Federal Aviation Administration (FAA) is moving toward the adoption of ICAO’s flight plan form for domestic use in the United States. This would replace the familiar FAA Form 7233-1 currently used by U.S. pilots for both VFR and IFR flight planning.
Title 14 CFR Part 91 currently requires pilots to file flight plans when conducting operations under instrument flight rules (IFR). Although optional, pilots are also encouraged to file flight plans for visual flight rules (VFR) operations. Given that many VFR flights are conducted without the use of air traffic control (ATC) services, a flight plan offers a tremendous safety benefit to the general aviation (GA) pilot by facilitating expeditious search and rescue operations, should they become necessary. Recognizing the potential safety benefits, there has been an industry-wide push to encourage the filing of flight plans for VFR operations.
Traditionally, pilots have utilized FAA Form 7233-1, which provides an intuitive and easy to use format for filing flight plans. Over the years, thousands of pilots have grown familiar with the current form, having used it from the time they were students. Should the proposed changes occur, pilots will be required to file their flight plans using the more cumbersome ICAO form.
As far back as 1997, AOPA was an active participant in the Air Traffic Procedures Advisory Committee (ATPAC), whose efforts were focused on addressing the issue of ICAO compliance with flight plan forms. Although the FAA touted the benefits associated with the ICAO format, AOPA was disturbed by the lack of consideration given to the potential impact on general aviation. With this in mind, the Multi-Agency Air Traffic Services Procedures Coordination Group Technical Working Group (MAPCOG TWG) was formed to address the concerns voiced by AOPA.
By 1999, the MAPCOG TWG had produced a consensus-based universal flight plan form that met the needs of all participants. This was seen as a reasonable compromise that would not only retain the simplicity of the current FAA form, but would also meet ICAO guidelines. At that time, the FAA also appeared to support the new flight plan format.
In an effort to clarify the administration’s intent, AOPA sent a letter to the FAA on June 13, 2000, reaffirming its support of the universal flight plan format developed by the MAPCOG TWG.
Three weeks later, a response was received from the FAA outlining its intent to move forward with the requirement to use the ICAO flight plan form. In its letter, the FAA cited international harmonization and the attainment of increased National Airspace System efficiencies as the primary motivators for this action. Although the FAA claims these efficiencies will ultimately benefit all stakeholders, it was not made clear how the ICAO form will help in achieving this objective.
While AOPA generally recognizes the safety and operational benefits afforded by harmonization throughout the aviation community, this particular initiative offers no foreseeable benefit to our members. Moreover, an FAA mandate to adopt the new ICAO flight plan form would require a significant pilot notification and re-education effort. With no clear incentive, the added complexity of the form would likely discourage many pilots from filing VFR flight plans. The impact to aviation safety would be immediate and profound, something both the FAA and AOPA wish to avoid. For these reasons, AOPA strongly opposes the requirement to use ICAO’s flight plan form for domestic operations.
If the FAA chooses to ignore the recommendations set forth by the MAPCOG, it would be discounting the needs of its largest customer, the general aviation community. Given that pilots are already required to file a FAA Form 7233-4 (ICAO format) for international flights, there would appear to be no benefit for any pilot in mandating usage of the ICAO form. If the FAA’s goal is to promote a seamless environment for airspace users, it should move forward with adopting the universal flight plan form. This will not only provide safety and operational benefits to the world’s largest and most active GA community, it would also conform to current ICAO needs.
Although the FAA appears to be moving forward with its implementation plan, they desire a meeting with AOPA to discuss future actions. We look forward to the opportunity to again express the aforementioned concerns on behalf of our members. Our goal is to continue promoting the consensus-based universal flight plan form, which will complement planned system enhancements without placing an undue burden on the GA community.
November 30, 2000, update: At the request of the FAA, AOPA representatives met with officials from the Air Traffic Procedures (ATP) office to assist in future harmonization efforts. The challenges associated with the transition to a new ICAO-compliant flight plan form were discussed at length. As a result of this initial meeting, three potential options were put forth, including:
Although each of these options will be reviewed in subsequent meetings, AOPA is pleased to see that the FAA is once again open to the idea of implementing the MAPCOG-supported universal flight plan form.
February 8, 2001, update: The FAA has agreed to keep the current domestic flight plan form as long as it is technically feasible.
In a January letter to AOPA, the FAA said, “We are pursuing the development of an automation approach that will permit pilots filing flight plans whose routes of flight will remain with domestic airspace under either visual flight rules (VFR) or instrument flight rules (IFR) to continue to utilize the current FAA flight plan format.”
The FAA said pilots flying to destinations outside of U.S. airspace would be required to use the ICAO flight plan form.
December 20, 2007, update: As a risk-reduction measure for the October 2008 introduction of the En Route Automation Modernization (ERAM) the FAA will require a change in IFR flight plan filing in June 2008. Commencing June 29, the FAA will require that certain flights file IFR flight plans using the ICAO flight plan form. The FAA views this as the first step in transitioning the entire system from the current NAS flight plan form to the ICAO flight plan form. In June, if a pilot desires assignment of any routing containing an RNAV SID or RNAV STAR, they will need to file their flight plan with an ICAO form. Pilots will still be able to file with a NAS flight plan form, be assigned conventional routing, and amend their route requests through the controllers. This requirement is due to the fact that the ERAM system is unable to decipher the suffixes used in the NAS flight plan (/E, /J, etc.). GA flights will not be largely affected by this change due to the fact that RNAV SIDs/STARs are rarely assigned to them because of aircraft performance requirements. Concerns have been raised that there would be some transition difficulties with GA pilots because of the ICAO flight plan format.
Updated Tuesday, June 17, 2008
AOPA thanks our members for their continued support in protecting the freedom to fly.